A Comment on the Clean Hands Doctrine in International Law

Equitable principles are a part of international law. The International Court of Justice
("ICJ") has confirmed that "the legal concept of equity is a general principle directly
applicable as law."[1] Among those equitable principles that international tribunals have
applied is the concept that a claimant's claims may be barred due to its illegal conduct in
relation to the claims he brings. This concept is known as the "clean hands doctrine."[2] As
Sir Gerald Fitzmaurice has summarized:
'He who comes to equity for relief must come with clean hands'. Thus a State which is
guilty ...